“While ICBA supports ensuring that consumers are fully informed about the terms and conditions of overdraft programs, the association is deeply disappointed by the Federal Reserve Board’s decision to impose yet another costly requirement that will further burden America’s common-sense community banks and lead to less consumer choice. The final rule will be operationally challenging and expensive for community banks to implement to cover some but not all electronic transactions, as well as confusing and inconvenient for consumers. Under the new rule community banks will have to reevaluate their overdraft service offerings, which many consumers see as a valuable service.

“ICBA does, however, appreciate the Board’s decision to not adopt a final rule that prohibits banks from assessing overdraft fees when an account is overdrawn because of a debit card transaction hold exceeding the actual transaction amount. Given the technology barriers and the numerous operating and processing models, implementation of such a prohibition is virtually impossible.

“In light of these strict rules, ICBA urges lawmakers to allow community banks to comply with these new regulations and disclosure regulations in lieu of advancing additional and unnecessary legislation.”